Singapore Airlines Ltd — Hazardous Materials Safety Interpretation

Page 1• of Transportation U.S. Department 400 Seventh Street, S.W. Washinglon, D.C. 20590 Special Programs Research and Administration DEC 1 9 2000 Mr. M Chandran Senior Officer Ref. No. 00-0238 Singapore Airlines Ltd Airline House 05A Singapore 819829 Dear Mr. Chandran: This is in response to your letter dated August 4, 2000, regarding the classification and packaging of aircraft fuel control units under the Hazardous Materials Regulations (HMR; 49 as follows: CFR Parts 171-180). Your questions are paraphrased and answered 01. The Federal Aviation Administration published Dangerous Goods Advisory Bulletin (DGAB) 98-02 in 1998. addressed concerns over fuel control units being improperly This document packaged and leaking while in transportation. Have any amendments to DGAB 98-02 been published? A1. No. 22. The HMR and the International Air Iransport Association Dangerous Goods Regulations (IATA DGR) show different proper shipping names for fuel control units: "Fuel, aviation, turbine, engine" and "Dangerous goods in machinery or apparatus, " respectively. by using either description? Are we in compliance with the HMR A2. The shipping description "Dangerous goods in machinery or apparatus" was adopted into the HMR in a final rule published It is our opinion that "Dangerous goods in apparatus" is the on March 5, 1999 (Docket HM-215C; 64 FR 10742). more appropriate shipping description. Under the conditions specified in § 171.11 of the HMR, we recognize the International Civil Aviation Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air. Therefore, an aircraft fuel control unit may be shipped in accordance with the ICAO Technical Instructions or the HMR. requirements for fuel control units in the IATA DGR are the The classification and packaging same as those contained in the ICAO Technical Instructions.#

Page 2Q3. Is polystyrene acceptable as an absorbent material when packaged with a flammable liquid? A3. Polystyrene may be used as a absorbent material only if it conforms to the conditions prescribed in S$ 173.24 and 173.27. In § 173.24, paragraphs (e) (1) and (2) state that packaging material must be compatible with the lading. Section 173.27 (e) states that the absorbent material must be capable of absorbing without reacting dangerously with the be of further assistance. I trust this satisfies your request. Please contact us if we can Sincerely, Hollez. Mithill Hattie I. Mitchell Chief, Office of Hazardous Materials Standards Regulatory Review and Reinvention#

Page 3SINGAPORE AIRLINES LIMITED Stevens 173.222 Mr Ed Mazzullo U. S. Dept of Transportation Research and Special Dangerous Programs Administration Office of Hazardous Goods in 400 Seventh Street Materials Standards equisment S. W. Washington DC 20590 USA Machineryor apparatus 04 August 2000 shipping as Name Dear Mr Mazzullo, RE: -AA DANGEROUS GOODS ADVISORY BULLETI EF: DGAB 98-02 DD Apr 7, 199 SHIPPING OF FUEL CONTROL UNITS AND FUEL RELATED UNITS. With reference to DGAB 98-02 of April 7t* 1998, FCU containing aviation fuel can be prepared for transportation as follows: As per 49 CFR Fuel aviation, turbine engine, CL 3, UN1863. PG II or III Residue, last contained Fuel, aviation, turbine engine CL 3, UN1863, PG II or III OR As per ICAO/IATA Dangerous goods in apparatus, ID 8001 Dangerous goods in machinery, ID 8001 Th lanie to prop a is soon intere Hardes arenal Reguy tons. But fist appears in the at the us Edition of the DGR as ID 8001. Would appreciate your advice on the following: A. Are there any amendments to DAB 98-02? (though 49 CFR and IATA shows two different method of declering, are we contravening any law b eclaring and shipping the FCU, containing aviation fuel, under UN 1863 ComiCan POLYSTYRENE material be used as an absorbent material? Can it be packed with components containing flammable liquid. - Thank you in advance for your kind assistance. Yours Sincerely, Chandran M Chandran Senior Officer rline House 05 ingapore Airlines LI FAX: (65) 541 4950 E-MAIL: (65) 545 7548 chandran_muthusamy@singaporeair.com.sg irmail Transit Centre P O Box 501, Singapore 9181 Cable SINAIRLINE Telex 2124 irline House, 25 Airline Road Singapore 1781 Telephone 542333#

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Page 5." DATE RECEIVED COMPANY 12/07/2000 CONT. PERSON Singapore Airlines Itd MI. M. Chandran DHM20 PO Cushmac SEC 12/15/20 ENTERED SUBJECT units. Classification and packaging of aircraft fuel control PO/ROUTE DATE ASSIGNED DHM12 (Stevens) DATE DUE 12/07/2000 ADD'L DATE ASSGN DATE SENT OUT ADD'L DATE SENT OUT SUMMARY 'RACKER'S INI/DATE Logged in 12/07/2000 bsc#

Page 6SINGAPORE AIRLINES LIMITED Stevens 173.222 if Transportation Allo ad Special Dangerous Effech to azardous dministration Goods in h Street tandards equisment, Jur Lington DC 20590 Machineryor response apparatus 2000 Dear Mr Mazzullo, Shigpingz38 Name RE: AA DANGEROUS GOODS ADVISOR EF: DGAB 98-02 DD Apr 7, 199 - as foi leverence to DAB 98-02 of April 2 1998, FCU containing aviation fuel can be prepared for transportation As per 49 CFR Fuel aviation, turbine engine, CL 3, UN1863. PG II Or III Residue, last contained Fuel, aviation, turbine engine CL 3, UN1863, PG II or III OR As per ICAO/IATA Dangerous goods in apparatus, ID 8001 Dangerous goods in machinery, ID 8001 Would appreciate your advice on the following: A. Are there any amendments to DGAB 98-02? - although 49 CFR-and TATA shows two-different method-of declaring, are we contravening any law by declaring and shipping the FCU, containing aviation fuel, under UN 1863 Comcan POLYSTYRENE material be used as an absorbent material? Can it be packed with components containing flammable liquid. Thank you in advance for your kind assistance. Yours Sincerely, Chandran Singapore 819829 TEL: (65 545 4958 E-MAIL: (65) 545 7548 chandran_ muthusamy@singaporeair.com.sg Airmail Transit Centre ouse, 25 in Rood Singapore: 1741 alphone 512335#